Re: Consultation Paper (Revising the Canadian Food Inspection Agency's TSE import policy for small ruminants and their products)

Dear Dr. Lord:

We are writing on behalf of the American Sheep Industry Association, Inc. (ASI). ASI is the national trade association for the United States sheep industry representing more than 68,000 producers through our 43 State affiliates. ASI appreciates the opportunity to comment on this consultation paper and the associated draft import conditions.

Canada is an important trading partner to the United States. U.S. sheep producers, feeders, processors and marketers have historically enjoyed positive trade relations with their Canadian counterparts and customers. In recent years, trade has become more difficult primarily due to BSE being diagnosed in cattle. ASI appreciates the Canadian Food Inspection Agency's (CFIA) and the U.S. Department of Agriculture's (USDA) diligence and their thoroughness in examining each North American case, the epidemiological investigations and the reporting of on-going progress to our respective livestock industries and the international community. We also appreciate CFIA proposing to revise the Canadian import requirements for sheep and goats as well as their associated products.

Approximately five years ago, the USDA in partnership with State animal health officials and the U.S. sheep industry, began the National Scrapie Eradication Program (NSEP). The NSEP is an aggressive, nation-wide regulatory program designed to find and eradicate scrapie from the United States by the year 2010 and with a subsequent seven-year monitoring and surveillance program, provide for international acceptance of scrapie-freedom by 2017. In the early phase of the NSEP, USDA conducted a national scrapie surveillance study. The surveillance study demonstrated an overall prevalence rate of .2 percent. As a key component of the NSEP, USDA conducts on-going targeted surveillance of adult sheep at a monthly rate of over 3,000 head. This fiscal year, USDA will conduct a national goat surveillance study also. At mid-term in the original NSEP plan, surveillance and diagnostic data show that the current prevalence rate has been reduced by about 50 percent. Although the NSEP is designed to eradicate scrapie, the only known TSE in sheep and goats, the surveillance system and regulatory program would find and remove TSEs in general from U.S. sheep and goat operations.

We suggest if the animals are shipped in a sealed means of conveyance to a slaughtering establishment and have met the appropriate conditions of entry that individual identification may not be necessary.

We recommend that as a condition of entry for slaughter, the country or zone from which the animals originate should have in place an enforced ruminant to ruminant feeding ban, a valid TSE surveillance program (that includes small ruminants), regulations and enforcement that scrapie is a compulsory notifiable disease, and that if TSE is found to be present, that an effective eradication program is in place and any affected animals are slaughtered.

Animals for Feeding for Slaughter:

We suggest that it is most important that a permanent mark be applied to each animal indicating its country of origin to help assure that sexually intact animals do not enter breeding flocks.

As indicated above for animals imported for immediate slaughter, the country or zone from which the animals originate should have in place an enforced ruminant to ruminant feeding ban, a valid TSE surveillance program (that includes small ruminants), regulations and enforcement that scrapie is a compulsory notifiable disease, and that if TSE is found to be present, that an effective eradication program is in place and any affected animals are slaughtered.

Live Ovines Imported for Breeding Purposes:(We assume this refers to ovine and caprine and that the requirements are meant to be the same.)

As stated above regarding slaughter and feeder animals, we believe that certain, basic conditions should be met in order for any animals to be imported, including animals from a country classified as negligible risk for TSEs. These include: an enforced ruminant to ruminant feeding ban, a valid TSE surveillance program (that includes small ruminants), regulations and enforcement whereby scrapie is a compulsory notifiable disease, and that there exists in the exporting country a veterinary infrastructure that is sufficient for enforcement, etc.

Males:

We recommend that CFIA include some risk-mitigation measures. It is generally assumed that males are very low risk for transmission; however, we believe that it would be wrong to assume that the risk is zero.

Females:

We agree that this category of animals should have individual identification and that the means of identification should be sufficiently permanent to provide for subsequent inspection and surveillance.

TSE-Free Establishments:

We recommend that the recognition of TSE-free status include a seven-year monitoring and surveillance period and necropsy of found-dead animals, as this is consistent with the World Organization for Animal Health guidelines. The U.S. scrapie flock certification program has included a five-year monitoring period like Canada's; USDA is in the process of changing our program to make it consistent with international guidelines.

Mention is made of "equivalent status." We recommend that CFIA further define equivalency with specific criteria.

We strongly discourage CFIA from the importation of animals from categories other than certified TSE-free under World Organization for Animal Health guidelines.

We agree that official inspections are an integral component of a valid certification program. However, we suggest that rather than specifically requiring a CFIA Official Veterinarian do the inspections, that either an Official Veterinarian of CFIA or an animal health professional under the direction of a CFIA Official Veterinarian should be able to provide inspection services.

Live Ovines/Caprines for temporary stay:

We recommend that these animals receive permanent identification of country of origin and flock of origin, as post-entry loss of identity could be a problem.

We also recommend that CFIA establish additional criteria for risk-mitigation (such as lack of exposure, flock exposure status, etc.) and restrictions against commingling both pre and post entry. In addition, we recommend that provisions be made for close monitoring of the reproductive status of the animals (some could be bred post-entry) and appropriate bio-security and clean-up measures listed should an animal give birth or abort.

We also recommend that time limits be placed upon imports for temporary stay. Since ultrasound pregnancy diagnosis is accurate only after several weeks post-conception, a time limit for temporary stay of several weeks but well short of the normal gestation period might be appropriate.

Transshipment:

We recommend that specific requirements be established for handling female animals in transshipments. Also specified facilities for off-loading and temporary housing, should it be necessary, and disposal/disinfection requirements should be prescribed, in our opinion.

Embryos:

We agree with CFIA's description of the requirements for the entry of embryos including our comments above regarding breeding animal importation.

Semen:

ASI recommends that additional criteria be established including: a prohibition of semen that is collected from animals that exhibit clinical signs (though semen collection on clinical animals is unlikely) or from animals that were confirmed as infected (including semen from animals that were clinical or determined to be infected that were collected earlier and the semen stored).

Meat:

We suggest adding more explanation in this section. In addition to prohibiting meat from test positive animals and animals over 12 months of age, criteria such as: the meat must have originated from animals in countries where a ruminant to ruminant feeding ban is in place and enforced and that the animals passed antemortum inspection.

Sincerely,

Paul R. Frischknecht President

ASI

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